MiCA Regulation in Romania: Licensing, implementation, and what crypto firms need to know

Imagine launching your crypto service in days, not months—Romania’s MiCA playbook makes it possible. As of 30 December 2024, the EU’s Markets in Crypto-Assets Regulation (MiCA (EU) 2023/1114) created a harmonized framework for digital assets. Romania didn’t wait to see how the rest of the bloc would fare. In mid-2025, it enacted Emergency Government Ordinance 10/2025 (OUG 10/2025), shifting licensing from a permission-gate model to a compliance-driven fast track. 

In this deep dive, I’ll walk you through Romania’s unique approach, show you who does what, and share exactly how your firm can go live under MiCA.

Romania’s swift embrace of MiCA sets a new standard for crypto regulation

You’ll see that MiCA applies directly in every EU Member State from 30 December 2024, with issuer-specific rules for asset-referenced tokens (ARTs) and e-money tokens (EMTs) effective from 30 June 2024. 

Romania flipped the switch further in June 2025 via OUG 10/2025, removing red tape and replacing it with real-time compliance. Instead of waiting in a licensing queue, you demonstrate governance, prudential and AML/CFT (anti-money-laundering and counter-financing-of-terrorism) controls from day one. 

The result? You can live fast—if your dossier is solid. Don’t worry, you won’t need a law degree to follow along.

How Romania’s dual-regulator framework delivers holistic oversight

Romania relies on three bodies to keep crypto markets robust. The Financial Supervisory Authority (ASF) authorises and supervises non-bank CASPs (Crypto-Asset Service Providers). The National Bank of Romania (BNR) oversees credit institutions offering crypto services and issuers of ARTs/EMTs, ensuring prudential stability. The Authority for the Digitisation of Romania (ADR) must pre-approve your IT systems—think cybersecurity, resilience testing and data-centre diagrams—before ASF sees your file. It’s like getting a GPS beacon and lifeboat certified before departure.

PRO TIP

Engage ADR as soon as you draft your ICT architecture. Their upcoming orders will spell out exactly what resilience reports and penetration tests they expect.

Compliance-based fast-track registration redefines licensing under OUG 10/2025

You no longer stare at a blank screen waiting for approval. Once ADR signs off on your tech, you file a complete registration dossier with ASF—and you can start operations immediately. 

The “no-pause” model rewards firms that prepare thoroughly, shifting emphasis to the quality of your governance, prudential, and AML/CFT controls from Day 1. Compared to traditional licensing, this is a high-speed compliance sprint rather than a marathon of administrative holds. If you love efficiency, you’ll love this.

Core registration dossier requirements

To jump the line, you need a robust dossier covering the following areas:

• Program of activities. Outline your services, business model, target markets and any cross-border plans.
• Governance & fit & proper. Provide an org chart, defined compliance and risk roles, conflict-of-interest policies, and integrity attestations for senior managers.
• Risk management & AML/CFT. Detail customer-due-diligence procedures, transaction-monitoring systems and Travel-Rule compliance per AML Law 129/2019.
• Technical & operational resilience. Submit ICT-architecture diagrams, cybersecurity controls, penetration-testing reports, plus business-continuity and disaster-recovery plans.
• Prudential resources. Show tiered own funds (€50 000–€150 000), client-asset segregation and cold-wallet insurance where relevant.
• White paper & disclosure (ART/EMT Issuers). Present standardized disclosures on token rights, fees, governance, redemption and risk factors.
• Supporting documentation. Include incorporation evidence, audited financial statements and professional-liability insurance.
  

PRO TIP

Bundle audited statements and insurance certificates in a single, bookmarked PDF for easy navigation by ASF reviewers.

Transitional arrangements provide breathing room for AML-regime entities

If you were registered under Romania’s AML regime by 30 December 2024, you get an automatic “grandfather” window until 1 July 2026—provided you submit your ASF dossier by 31 December 2025. This aligns with MiCA’s 18-month fallback and gives you time to stress-test your systems in production before full MiCA supervision kicks in.

PRO TIP

Run live simulations of your transaction-monitoring system at peak volumes during this window. Demonstrating resilience under load will earn brownie points with ASF auditors.

Strategic steps for crypto firms to navigate Romania’s MiCA regime

Here’s your action plan:

1. Secure ADR’s sign-off on your tech blueprint.
   
2. Compile a complete, consistent dossier for ASF.
   
3. Design AML/CFT and Travel-Rule systems to meet MiCA standards from day one.
   
4. Build governance structures with clear fit & proper attestations and conflict-of-interest policies.
   
5. Document operational-resilience measures—penetration tests, redundant infrastructure and incident-response plans—as non-negotiables.
   
6. Meet capital thresholds, segregate client assets and insure cold wallets.
   
7. After ASF registration, enjoy EU passporting: offer services across all 27 Member States without additional licences.
   
8. Prepare for rigorous post-registration supervision by ASF and BNR via ESMA channels.

PRO TIP

After you’re live, run quarterly internal audits of your MiCA controls. It shows proactivity and builds trust with both ASF and BNR supervisors.

Streamline MiCA compliance with CyberUpgrade

Meeting MiCA’s rigorous requirements—from whitepaper filings to ongoing governance and transparency—often means endless manual tracking and audit prep. CyberUpgrade automates your MiCA workflows with prebuilt templates and real-time Slack or Teams prompts, keeping policies, risk assessments, and evidence audit-ready in one central hub.

Beyond MiCA, CyberUpgrade also supports DORA, ISO 27001, and NIS 2 frameworks, letting you “map once, prove many” across multiple regulations. Automated data extraction, vulnerability scans, and KPI dashboards feed each regulator’s portal seamlessly, reducing manual work by up to 80 %.

With fractional CISO services guiding your continuous monitoring and customizable compliance workflows, you’ll secure faster approvals, avoid fines, and adapt as MiCA and related frameworks evolve—turning compliance from a hurdle into a strategic advantage.

Eye on the horizon: Positioning your crypto venture for Future EU rules

With OUG 10/2025, Romania set a new benchmark for fast, compliance-focused market entry under MiCA. By aligning your governance, AML/CFT, technical resilience and capital structures with MiCA’s standards—and leveraging the transitional period—you’ll tap into over 500 million EU consumers almost instantly. 

Next up on the EU agenda: pilot regimes for decentralized finance and new AML amendments. Keep a dedicated regulatory-watch channel in your governance team to spot changes early. That way, you’ll be riding regulatory waves rather than fighting them.